Tag Archives: Emergency Preparedness

Emergency Preparedness

How to conduct a Hazards and Vulnerabilities Risk Assessment

Look for this picture on the Home Health Solutions Facebook Page every day during our 10-day Countdown to Emergency Preparedness and comment to win helpful EP products! 

THURSDAY, Oct. 19 Giveaway
TIP #4: WHAT COULD POSSIBLY GO WRONG?

One of the key components of new Emergency Preparedness Programs which CMS is requiring home health agencies to have in place by the November deadline is an All Hazards Risk Vulnerabilities Assessment.

If you’re still wondering exactly this is and where your agency can download its risk assessment form, we have some disappointing news. There is no standard risk vulnerabilities assessment form agencies can download and fill out to comply. CMS leaves the actual format of the risk assessment – whether it will be a form or even a full, written report with a chapter-by-chapter analysis — to the discretion of the home health agency.

You will see many different versions and samples of suggested risk assessments all over the internet, ranging from basic to complex.

(Because we like things made easy, and because we believe Surveyors appreciate being able to quickly find information, Home Health Solutions suggests using an easy-to-read form for the risk assessment. We provide a fairly simple form in an easy-to-follow 12-step Emergency Preparedness Plan Assembly Kit we sell in the HHS online store.)

Whichever format your risk assessment takes, bear in mind that the easier it is to read, with information presented clearly and concisely, the more likely Surveyors are to look at it favorably. Surveyors are human, too – and no one likes wading through a disorganized mess or too much information.

CMS does provide some guidance about the risk assessment. Your agency will need to determine your vulnerability (based in large measure on your geographic location and the history there of previous events) to all natural or man-made disasters, including weather-related catastrophes such as winter storms, tornadoes, hurricanes, flooding, wildfires, etc. You’ll also need to evaluate your vulnerability to non-weather emergencies, such as nuclear power plant explosions or acts of terrorism.

Each agency’s risk assessment will be based on your particular location and the likelihood of hazardous conditions for you. An agency in North Dakota, for example, will probably devote a great deal of space on its risk assessment to the likelihood of winter storms, so that it can undertake detailed planning for continuity of patient care during ice or blizzards. But an agency in Florida will almost certainly devote most of its space to tropical storms or hurricanes with the potential for high winds and flooding – and may even devote space to the potential for sinkholes.

Your agency’s risk assessment shouldn’t necessarily look just like assessments for other agencies in your state. Is your agency located within a few blocks of a major metropolitan airport? You may want to include the possibility of a major plane crash impacting the building in which your agency is housed. Does the river in your small town flood in years with heavy spring rains, closing roadways? Your risk assessment should highlight that risk. Do frequent rock slides impact roadways in the mountainous areas where you serve clients? That is a risk specific to your area, and should be addressed in your risk assessment.

Remember that CMS loves data, so build your risk assessment to the extent possible around local data showing previous incidences of ice storms, tornadoes, forest fires, etc. which have occurred in your area. Your local Emergency Management Agency should be able to help provide data, or direct you to state web sites where it can be found.

Bear in mind, however, that your risk assessment does not need to be a lengthy and detailed incident report of every power outage or tornado watch experienced in your area over the last few decades. You will only need to provide a comprehensive overview of risks specific to your area.

Think of the risk assessment as your agency’s clear, concise and carefully constructed answer to these two questions:

1. What could possibly go wrong?

2. How will we respond if it does?

The goal is to demonstrate that you have thoughtfully and carefully evaluated many different situations likely to make it difficult for you to care for your patients, seeking input from qualified emergency management officials who are trained in dealing with crisis situations, and that you have set in place mechanisms to maintain continuity of care even under the most challenging circumstances.

CMS specifically uses the term “all hazards” in defining the risk assessment, so be sure to weigh all potential hazards, including those which are not weather related. Your assessment should reflect your agency’s vulnerability to cyber attacks, workplace shootings, hostage situations, acts of terror and other man-made crises which could negatively impact your ability to care for your patients.

On its web site, CMS says the risk assessment should include (but is not limited to):

  • Hazards likely in geographic area
  • Care-related emergencies
  • Equipment and power failures
  • Interruption in communications, including cyber attacks
  • Loss of all/portion of facility
  • Loss of all/portion of supplies

The CMS list above provides the framework for your risk assessment. Flesh it out and make it specific to your agency, and you will have this important element of your Emergency Preparedness Program in place.

The clock is ticking. Check out all the helpful CoPs products HHS offers in our online store, The Solutions Shop: www.homehealthsolutionsllc.com/the-solutions-shop

Emergency Preparedness

CMS requires two exercises before November deadline

Look for this picture on the Home Health Solutions Facebook Page every day during our 10-day Countdown to Emergency Preparedness and comment to win helpful EP products! 

WEDNESDAY Oct. 18 Giveaway
TIP #3:  WAIT. A FULL-SCALE DRILL BY WHEN?

Are you still working hard to get your home health agency’s new Emergency Preparedness Program in place by November so that you can meet the CMS deadline and begin all the detailed planning for those two exercises you’re required to stage — the full-scale community disaster drill and a second, smaller-scale  table-top exercise?

We sure hope not.

For compliance, your agency will need to have already staged both these required exercises by November. The Emergency Preparedness Requirements Final Rule was posted to the Federal Register more than a year ago, on Sept. 8, 2016, and the regulation went into effect just two months later, on Nov. 16, 2016. Medicare and Medicaid Participating Providers and Suppliers were given one year from the effective date to comply and implement all regulations. When that year is up – in just one more month – home health agencies will be subject to citations for non-compliance if they have not yet staged both exercises this past year.

The Emergency Preparedness Requirement was confusing to many home health agencies. We talk to agencies every day who are so busy caring for patients and taking care of agency business that they have trouble juggling regulatory deadlines – especially this year, when the start date for new Conditions of Participation was originally set for a July implementation, and then delayed until January.

Isn’t the Emergency Preparedness requirement part of the new CoPs, agencies ask us. Don’t we have until January now? Not for your Emergency Preparedness Programs, we explain.

While the Emergency Preparedness requirement is included as part of the new CoPs, and while  the start date for CoPs was pushed back six months, a delay was never granted for the original Emergency Preparedness Requirements Final Rule which posted to the Federal Register back in 2016.

The clock began ticking then.

Time is up.

Some agencies which experienced actual emergencies this year may be exempt from the community-wide disaster drill (please see Tuesday’s Tip #2).

But agencies which did not activate emergency plans this year and conduct an evaluation afterward are expected to comply with the full-scale community-wide drill prior to next month’s deadline.

In either case, agencies also will be expected to have staged tabletop exercises, in which mock disasters are conducted via paper.

If you’re feeling panicked by the approaching deadline, please visit our online store today and check out our 12-step Emergency Preparedness Plan Assembly Kit. We’re not going to mislead you; it’s getting late in the game to comply, and it will be very difficult now to meet the deadline if you have not yet begun. But don’t wait another day. Our Kit will make it faster and easier.

Click here to visit The Solutions Shop, our online store. 

 

Home Health Emergency Preparedness, Uncategorized

Tip: CMS offers exemptions to the Community-Wide Disaster Drill

Look for this picture on the Home Health Solutions Facebook Page every day during our 10-Day Countdown to Emergency Preparedness and comment to win helpful EP products! 

Tip #2: Full-scale exercise exemption
TUESDAY OCT. 17 GIVEAWAY: Our helpful EP Guide to Survey Readiness

Of all the new Emergency Preparedness requirements expects home health agencies to meet by November, the community-wide disaster drill (full-scale exercise) is the most intimidating and labor-intensive for many agencies.

The community-wide drill is one of two exercises CMS expects home health agencies to stage each year. The second exercise may be a tabletop version, in which the emergency situation is plotted out via paper-only, with participants seated around a discussion table and “talking out” the procedures.

But the community-wide drill is a full-scale exercise requiring agencies to work with other agencies in their communities such as first responders, emergency management officials, hospitals, clinics, assisted living facilities and others to stage a mock crisis, and conduct a detailed evaluation afterward of how well things went, identifying areas for improvement.

The drill is a major undertaking, requiring much planning and coordination.
Did you know, however, that your agency may be exempt from the community-wide drill until next year if you experienced a crisis which required activation of your Emergency Plan? Many agencies in Florida, Texas, Louisiana, South Carolina and Georgia as well as agencies in the Virgin Islands and Puerto Rico were required to activate emergency procedures during this fall’s spate of damaging hurricanes.
 Wildfires in California are currently threatening areas served by home health agencies.

If your agency is located in one of these affected areas – or if you are located in a different area of the country where you experienced a crisis such as tornadic activity, flooding, a blizzard or any other emergency which required your agency to activate emergency procedures – you appear to be exempt from staging a community-wide disaster drill before Nov. 16.

Documentation of the activation of your emergency procedures will be required, as well as a thorough evaluation afterward.

Note that you will still need to have conducted a tabletop exercise by the deadline in order to be compliant.

Here is what CMS says on its web site about this exemption:

NOTICE ON TRAINING & EXERCISES: If a facility activates their emergency plan due to a disaster, the facility is exempt from one full-scale/individual based exercise for that year. However, the secondary requirement for a table-top exercise or exercise of choice still applies. Facilities must demonstrate completion of two exercises per annual year.

You can read for yourself what CMS says about the full-scale exercise at:
https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule.html

Emergency Preparedness

HHS Countdown to Emergency Preparedness offers tips and giveaways

Look for this picture on the Home Health Solutions Facebook Page every day during our 10-Day Countdown to Emergency Preparedness and comment to win helpful EP products! 

Tip #1:  Are your patients prepared?
MONDAY OCT. 16 GIVEAWAY: Our helpful EP Guide to Survey Readiness

CMS wants to make certain home health agencies have adequately prepared patients and their caregivers for the possibility of evacuation or other possible changes in the delivery of care during or immediately after an emergency situation.

One of the ways agencies should do this is by providing patients two lists: a Medication List and a Special Equipment List. These lists are to be kept in the home and constantly updated so that each list is always current. This means it will be necessary to review and update the Medication List at each visit – a big change for most agencies.

Make certain patients and caregivers understand that these lists are to go with them to a shelter if an evacuation is needed.

The Medication List should include the medication, dose, frequency, route, time of day, and any special considerations for administration. The Special Equipment List will identify the equipment needs of the patient.

Note that lists should include the name and phone number of the patient’s physician and pharmacy, and the address of the pharmacy should also be included.

It is also important to include allergies and adverse events as well the name and contact information for the home health agency on these lists.

During the confusion of an emergency situation, this information could be vital to maintain continuity of care for the patient.  HHS recommends that your agency create a form to be used to collect all the necessary information, so that nothing will be inadvertently omitted.

Be sure to document your discussions with patient and caregivers about the importance of these lists, with reminders that the lists should always travel with the patient if there is an evacuation.

Preparing homebound patients for the possibility of an emergency situation is an important step in your agency’s overall Emergency Preparedness Program. 

Read more tips and enter to win daily giveaways on the Home Health Solutions Facebook Page during our “10-Day Countdown to Emergency Preparedness,” as we help home health agencies meet the CMS deadline to have Emergency Preparedness Programs in place. 

Conditions of Participation, Home health agencies, Uncategorized

No Emergency Plan yet? Programs must be in place by November 15, 2017


Last month’s reprieve from continuing pre-claim review demonstrations by the Center for Medicare and Medicaid Services and the announcement that CMS is considering a delay in the start date for new Conditions of Participation has created a sense of cautious relief in the home health field.

Many home health professionals are wondering if the reprieves and delays reflect a trend away from increasingly stringent compliance demands on home health agencies in recent years.

But gambling on the advent of a more relaxed regulatory climate could have negative consequences for agencies – including CMS citations for non-compliance beginning in November for agencies failing to meet new Emergency Preparedness Program requirements, warned J’non Griffin, president and owner of Home Health Solutions LLC.

“It’s really important not to lose our sense of urgency in home health,” J’non said. “Emergency Preparedness Programs should be a priority for agencies right now. The programs take a while to put into place, and CMS has said that agencies will be expected to meet EP requirements by Nov. 15, 2017, or be cited for non-compliance.”
A proposal CMS is now considering to push back the start date for revised Conditions of Participation is not expected to impact the Nov. 15 effective date for Emergency Preparedness Programs.

“This means that regardless of whether CoPs are implemented on July 13, 2017, or pushed back six months until January, 2018, home health agencies will need to have in place their Emergency Preparedness Programs by this November,” J’non said.

Community wide disaster drills

To avoid non-compliance, beginning Nov. 15, agencies will need to have already conducted the community-wide disaster drills which are part of the CMS-mandated Emergency Preparedness Programs.

This requirement has been one of the most intimidating to many agencies, according to J’non, because it requires them to pool efforts with local and state emergency agencies and health care coalitions to conduct full-scale community exercises.

Under the Final Rule mandating home health Emergency Preparedness Programs, two of these drills are required annually for agencies to test their emergency operations, although one of the drills may be a tabletop exercise.  Agencies experiencing real emergencies may be excused from one of the required yearly drills.

Some agencies have not yet begun efforts to coordinate the disaster drills because they are hoping additional guidance will be provided when interpretive guidelines for the new CoPs are issued.

“Agencies really shouldn’t wait for interpretive guidelines to be issued. CMS has specifically addressed this issue, stating that agencies must perform their community wide disaster drills by Nov. 15,” J’non said.

On its web site, CMS states:

“We realize that some providers and suppliers are waiting for the release of the interpretive guidance to begin planning these exercises, but that is not necessary nor is it advised. Providers and suppliers that are found to have not completed these exercises, or any other requirements of the Final Rule upon their survey, will be cited for non-compliance.”

Agencies unable to comply

Agencies unable to conduct a community-based exercise by the deadline may be able to document why and avoid citation for non-compliance as long as reasons are valid, J’non said.

In rural areas, for example, agencies may not have access to the same resources as agencies in more populated areas. In a community in which an annual disaster drill is already scheduled to take place after the Nov. 15 deadline, it may make more sense for an agency to wait and join existing community efforts.

Agencies who find themselves in these or other situations which hinder efforts to comply with the disaster drill mandate must thoroughly document efforts to coordinate a community wide drill, explaining why it was not possible within the time frame, according to J’non. They will still need to conduct and document a facility-based disaster drill, she said.

On its web site, CMS identifies these documentation requirements:

“The documentation should include what emergency agencies and or health care coalitions the provider or supplier contacted to partner in a full-scale community exercise and the specific reason(s) why a full-scale exercise was not possible.”

Where to find help

Home Health Solutions offers an Assembly Kit that breaks down the development of an Emergency Preparedness Program into 12 easy-to-follow steps, offers a Sample Plan to follow, and provides more than 30 assessment tools and forms which will be needed to capture the right information for creating a fully compliant Emergency Preparedness Program.

It’s designed to simplify the process for busy agency executives with a format anyone can easily follow to meet CMS requirements.

The Assembly Kit can be purchased at: www.homehealthsolutionsllc.com/solutions-shop

The CMS web site offers resources such as checklists, links to emergency preparedness agencies, planning templates and many other aids to assist agencies in developing Emergency Preparedness Programs.  The website also provides a State-by-State listing of Health Care Coalitions. The information can be found at:

https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule.html.